The Madhya Pradesh High Court has held that a decree holder cannot frustrate the terms of a compromise decree or trigger execution proceedings by deliberately refusing to accept or encash a cheque tendered by the judgment debtor in lawful satisfaction of the decree. Under the compromise decree, Partha Credit became the judgment debtor, and Ideal Electronics became the decree holder. This demand was contested by Partha Credit on ground that no interest was stipulated in the compromise decree of July 18, 2021. Thus, Partha Credit applied Section 47 CPC before the Trial Court, questioning the maintainability of the execution filed by Ideal Electronics. Applying these principles, the bench held that the judgment debtor has duly satisfied the compromise decree by depositing the entire amount within the stipulated period.